Code of Ethics

PRIMESolutions Advisors has a position of public trust and it is the Adviser’s goal to maintain that trust; provide excellent service, good investment performance; and advice that is suitable.

PRIMESolutions Advisors takes the issue of regulatory compliance seriously and is committed to stay in compliance with state and applicable federal securities laws. PRIMESolutions Advisors places great value on ethical conduct. Therefore, the ultimate goal of our Code of Ethics and internal policies and procedures is to not only live up the letter of the law, but also to the ideals set forth by the Adviser.

PRIMESolutions Advisors is a fiduciary to each and every client. Investment Advisers owe their clients several specific duties as fiduciaries. According to the United States Securities Commission (“SEC”) and state securities regulators, an Investment Adviser’s fiduciary duties include:

Advice that is suitable

Full disclosure of material facts and potential conflicts of interest (such that the client has complete and honest disclosure in order to make an informed decision about services of the Adviser and about investment recommendations)

Utmost and exclusive loyalty and good faith

Best execution of transactions

The Adviser’s reasonable care to avoid ever misleading clients

Only acting in the best interests of clients

It is PRIMESolutions Advisors’ policy to protect the interests of each of the Adviser’s clients and to place the clients’ interests first and foremost in each and every situation.

PRIMESolutions Advisors will abide by honest and ethical business practices to include, but is not limited to:

The Adviser will not induce trading in a client’s account that is excessive in size or frequency in view of the financial resources and character of the account.

The Adviser will make investment decisions with reasonable grounds to believe that the decisions are suitable for the client on the basis of information furnished by the customer and we will document suitability.

The Adviser and its Advisory Representatives will not borrow money from clients.

We will not recommend the purchase of a security without the reasonable belief that the security is registered, or the security or transaction is exempt from registration in states where we provide investment advice and based upon information the Adviser receives.

We will not recommend that the client place an order to purchase or sell a security through a broker/dealer or agent, or engage the services of a broker/dealer that is not licensed, based upon information available to the Adviser.

The staff of the Adviser will report all personal securities trading to Sam D’Alesandro, the Chief Compliance Officer as required by the SEC.

PRIMESolutions Advisors requires that all supervised persons immediately report any known or suspected violations of the Adviser’s Code of Ethics or securities rules and regulations, to Sam D’Alesandro. Failure to report material information will result in loss of authority or termination and possible additional action by regulators.

If you should have any questions about how PRIMESolutions Advisors does business or if you have any concerns during the course of our relationship, we want to hear from you.